BIO Comments on EPA’s 2013 Renewable Fuel Standard (RFS) Rules
The Biotechnology Industry Organization (BIO) recently submitted comments to the Environmental Protection Agency (EPA) on the proposed Regulation of Fuels and Fuel Additives: 2013 Renewable Fuel Standards (RFS).
The comments emphasized that continued stable implementation of the RFS provides companies developing innovative new advanced and cellulosic biofuels confidence that the U.S. fuel market will remain open, if they can produce the fuels. “BIO supports EPA’s continued recognition that many factors must be taken into consideration in developing projections of the proposed Cellulosic Biofuel Volumes for 2013, and that information obtained directly from cellulosic biofuel producers should be evaluated in addition to the U.S. Energy Information Administration’s (“EIA”) estimate,” said Brent Erickson, executive vice president of BIO’s Industrial & Environmental Section.
BIO also cautioned against setting volumes for cellulosic and advanced biofuels that would become a self-fulfilling prophecy, by discouraging biofuel developers from aiming higher. “EPA also correctly observes that perennial legal and legislative challenges to the RFS, and budget and regulatory uncertainty in complementary federal biofuels policy, have caused some technology investors to question the long term RIN value of cellulosic biofuel. However, EPA must carefully avoid in its rulemaking creating additional incentive for biofuel opponents to impede cellulosic biofuel commercialization through legal, regulatory and legislative interference,” Erickson wrote.
BIO also recommended that EPA not set the 2014 volumes for the RFS advanced biofuel volumes before the statutory deadline. And in response to requests for comments on the “blend wall,” Erickson noted: “BIO firmly believes that the limits to market access for biofuels commonly referred to collectively as the blendwall represent a series of barriers contrived by obligated parties to prevent biofuels from gaining access to the marketplace. Multiple avenues exist for blending additional volumes of biofuel into the nation’s fuel supply.”